Jeffrey Guerrero hired James McDonald, a certified public accountant, to represent him and his business in an appeal to the Internal Revenue Service. The appeal was about audits that showed Guerrero owed more taxes. When the appeal failed, McDonald helped Guerrero prepare materials for an appeal to the Tax Court, which was also unsuccessful. Guerrero then sued McDonald for professional negligence in the preparation of his evidence for the court. Guerrero claimed that McDonald had failed to adequately prepare witnesses and to present all the arguments that could have been made on his behalf os that he could have won the case. Guerro contended that McDonald was liable for all the additional taxes he was required to pay.

$1)$ Explain the potential professional liability CPAs are exposed to for violating federal tax laws, and cite relevant sections of the code.

$2)$ Determine whether the CPA is liable for the additional taxes owed by the client in this instance, and explain your reasoning.

a$.$ Apply relevant internal revenue code and regulations in your decision, and explain your rationale.

b$.$ Cite the relevant sections of the internal revenue code and regulations.